Place of Processing Customisation for Google Services

As January 22nd, Google has updated the contracting party for all their services from Google LLC to Google Ireland Limited for all instances where End-users are based in the the European Economic Area (EEA) or Switzerland.

Below you’ll find highlighted portions of the notification email sent by Google.

Hello Administrator,

This email is to inform you about changes in our end-user facing Terms of Service and Privacy Policy for your users in the European Economic Area (EEA) or Switzerland that may affect and be noticed by users in your domain [redacted] as they access some of the Google Additional Services . . . For users in your domain that are based in the European Economic Area (EU countries, Iceland, Liechtenstein, and Norway) or Switzerland, starting January 22, 2019, services offered under the end-user facing Terms of Service will be offered by Google Ireland Limited instead of Google LLC. . . we’re also updating Google’s Privacy Policy for the Additional Services. The new policy specifies that Google Ireland Limited will be the data controller responsible for these users’ information and for complying with applicable privacy laws (unless otherwise stated in a service-specific privacy notice).

Do these changes affect you?

These changes may be applicable to you if you or any of your Users are based in the European Economic Area (EEA) or Switzerland.

Here some examples of when this change may apply to you:

You’re based in the European Economic Area (EEA) or Switzerland and have EEA or Switzerland-based users.

All your users are based in the European Economic Area (EEA) or Switzerland, regardless of where you are based.

You’re based outside the European Economic Area (EEA) or Switzerland, e.g the US, and your users are based both in the US and the European Economic Area (EEA) or Switzerland.

*If you’re not sure if you may have EEA or Switzerland based users, it’s best to err on the side of caution and assume that it applies to you as well.

As quoted above, Google’s changes automatically apply to all your EEA and Switzerland-based end-users, regardless of where you are based.

What do you need to do?

Because you’re legally required to correctly identify third-party processors, we strongly suggest that you update the clauses in your policies that are related to affected Google services to include “Google Ireland Limited”.

Google Ad Manager

Google Ad Manager Audience Extension

Google Ads conversion tracking

Google Ads Remarketing

Google AdSense

Google Analytics

Google Analytics for Firebase

Google Analytics with anonymized IP

Google App Engine

Google Calendar widget

Google Cloud Storage

Backup on Google Drive

Google Drive account access

Google Fonts

Google Friend Connect

Google Hire

Google Maps widget

Google OAuth

Google Pay

Google Play Beta Testing

Google reCAPTCHA

Google Site Search

Google Tag Manager

Google Website Optimizer

Google+

Google+ +1 button and social widgets

Gmail

YouTube button and social widgets

YouTube OAuth

YouTube video widget

YouTube video widget without cookies

Firebase Authentication

Firebase Cloud Firestore

Firebase Cloud Functions

Firebase Cloud Messaging

Firebase Cloud Storage

(Firebase Crash Reporting – no longer available)

Firebase Dynamic Links

Firebase Hosting

Firebase Invites

(Firebase Legacy – no longer available)

Firebase Notifications

Firebase Performance Monitoring

Firebase Realtime Database

Firebase Remote Config

AdMob

FeedBurner

Blogger

Crashlytics

Beta by Crashlytics

Remarketing with Google Analytics

User ID extension for Google Analytics

Display Advertising extension for Google Analytics

Fabric Answers

If you’re based outside Europe and have users from both outside and within the EEA and Switzerland, you should consider adding both “Google Ireland Limited” and “Google LLC” using the method detailed below.

Changes to your Privacy Policy

To edit, simply go to the relevant site area in your iubenda dashboard and click on the “Edit” button for your privacy policy.

Next, click the pencil icon on the service you’d like to edit and simply click inside the “Select the region” field in order to update the information.

Click on “Save and Close” and you’re done.

Changes to your Cookie Policy

If you’re using a cookie policy generated by iubenda (pro feature), your cookie policy will be automatically updated to reflect the changes made in your privacy policy.

If you’re using an externally prepared cookie policy, you may need to seek legal assistance in order to manually update the relevant information.

Help

Country

The software, materials and assistance provided by iubenda have the only purpose of helping users with compliance regarding their legal requirements. In particular, the templates iubenda provides are generated automatically, yet every word of our template has been written and continuously revised by a skilled legal team. However, as can be easily understood, nothing can substitute a professional legal consultancy in the drafting of your privacy policy, cookie policy or of any other legal document or compliance procedure. Our service does its best to provide you with a starting point, like an extremely sophisticated templates book, but even if we strive to provide the best assistance possible, we cannot guarantee any conformity with the law, which only a lawyer can do. Nothing on this site, therefore, shall be considered legal advice and no attorney-client relationship is established. Please note that in some cases, depending on your legislation, further actions may be required to make your activity compliant with the law.